Author: Adam Morrison

Streamline Designs has experienced wonderful growth—especially over the past few years—largely because of the great support of the light aircraft industry and our long-standing customers. Many companies in the light aviation world have enjoyed the benefits of our love of provide enabling solutions for a wide range of aircraft manufacturers.

For some time now, Marcie and I have been looking to diversify Streamline Designs by leveraging our intimate knowledge of standards-making, product certification, and progressive systems thinking. We also want to “scratch the itch” of cross-pollinating ideas, tools, and technologies wherever possible, and even across different industries where it makes sense. In particular, we have always had a vision to leverage our design and engineering skills to develop hardware solutions.

As a small business, we have also looked for ways to grow Streamline Designs in our local community and in the context of our growing family. We’ve added staff, which has been a wonderful blessing. This has enabled us to reduce overhead and deploy some of our attention to the pursuit of enabling hardware-based solutions within aviation while continuing to fully serve you.

We are pleased to announce some of the fruit of that growth and diversification, as we just finished exhibiting at AUVSI XPONENTIAL in New Orleans with our very first hardware startup, DroneRafts LLC.

DroneRafts and the WaterStrider at AUVSI 2016

Our intent for this new venture is that it will grow into a lively partner for the hardware side of Streamline Designs, and as a strategic expansion of our newly modified scope: “Enabling Solutions for Things That Fly.”

Already, our thinking regarding standards and regulations for unmanned aircraft have our gears turning for manned aircraft and avionics certification opportunities. We want to assure you that Streamline Designs is alive, well, and growing and will continue to add value to our exiting and growing client base through our engineering consulting and industry involvement. We strongly believe that this new venture will only serve to make us stronger and more capable of serving your needs in creative ways.

We truly love things that fly and hope that you will share in our excitement. You can find out more about our new venture, DroneRafts LLC and on our live Kickstarter project for our new product WaterStrider™.

We’re trying to get the word out about this new and exciting product. Please share this and help us spread the word!

I also want to take a moment to express a heartfelt “Thank You” for believing in, supporting, and working with us as we have pursued our vision to provide truly enabling solutions for light aviation.

Introduction

Over the last several years there has been a great deal of back and forth over F2245 (Standard Specification for Design and Performance of a Light Sport Airplane). The Committee on LSA has always been viewed as a poster child for rapid development and flexibility, being “able to accelerate their standards writing activities and respond efficiently and effectively to marketplace needs.” But the downside of flexibility is the frustration of manufacturers at the mercy of a changing standard, who are sometimes required to make alterations to their aircraft and ultimately, their businesses. We’ve coined the term ‘ballot fatigue’ to capture the sentiment that some manufacturers are expressing regarding the pace of change.

How many changes have there actually been? And of what significance are they? What was the driver for the change initially? Given how frequently these questions are being asked, we set out to help provide some perspective for the answer—at least for the most frequently revised standard, F2245.

As seen in the figure, there is a consolidation process that occurs as ballots are approved, get published by ASTM, and the ultimately get accepted or recognized by Civil Aviation Authorities (CAAs). In the United States, for example, the twenty-seven approved change over the five-year period became real to aircraft manufacturers just four times through the FAA Notice of Availability process—a little less than once per year.

The categories of changes fall into six different categories, each outlined below.

Authority Request (33%)

Nine of these changes were made under the first and most common category, the Authority Request. One-third of the changes made were requested by a CAA. Seven of those ten were a direct result of the Zodiac CH 601 XL investigation. These standards changes included the addition of Operating Maneuvering Speed (VO), calibration of Airspeed Indication System and the elimination of inconsistencies in never-exceed speed (VNE) definition. The other authority requests were made for improving international applicability of the standard (consideration of variable pitch propellers and a new appendix for related requirements when an aircraft is equipped with a variable pitch prop).

Improvement (26%)

There were seven instances when the standards’ existing content was clarified or improved. Some of the items affected by this category of change include minimum useful load, glider towing operational and structural cone angles, and clarification of permanent deformation of structures at limit load. These changes were made to reduce and eliminate confusion.

Administrative (15%)

Four of the changes were made to adjust content between standards and/or sections for organizational purposes, often in light of the whole body of standards. When making an administrative change, the committee was diligent to look at all of the standards, not just F2245, when considering content. Sometimes one standard affects, clarifies or confuses another. Administrative changes are made to keep the body of standards running smoothly together. One of those changes involved references to Federal Aviation Regulations (FAR) and European Aviation Safety Agency (EASA) specifications. Two others resulted in harmonizing the information on nose gear loads and firewall thickness.

New Developments (7%)

Periodically new subjects or issues are brought to committee which are deemed appropriate and important enough to be included in the body of standards. When that happens, the change is categorized as a New Development. In the case of F2245 there have been two new developments in the past five years: the integration of electric propulsion and the requirement to use an approved propeller on LSA airplanes.

Editorial (4%)

Editorial changes are made when a correction or clarification of existing content doesn’t affect the meaning or technical aspects of the item at all. The lateral mass ratio equation in the appendices was corrected as an editorial change.

Conclusions

There have been a lot of ballots over a five year period which has created ‘ballot fatigue’. This is certainly unhealthy for the overall industry because people that are tired of reviewing ballots tend to take less care in commenting and voting. The committee leadership is regularly discussing this, putting tools in place, and deliberating carefully in selecting work each year. We have cataloged over one-hundred suggested changes across all of the F37 standards and spend significant time in each committee meeting reviewing the pros and cons of each item. Many items haven’t been pursued due to a lack of positive impact on the industry overall and a recognition of ‘ballot fatigue’. Some other observations follow below:

There have been between five and six successful ballot topics per year that have translated to a little less than one required change per year for US manufacturers and a total of two changes for European LSA. Other countries like China accept the ASTM-published changes immediately for Type Certificate and Production Certificate applicants. In frameworks like this, close attention to standards changes is important as a manufacturer nears the point of certificate issuance.

Fatal accidents have driven well over one-third of total balloting activity and about one-third of all accepted ballots. One key strategy for reducing ‘ballot fatigue’ is to design, produce, and support aircraft that are safe through true compliance to the standards.

Due to the nature of the ASTM process, there is ballot activity related to changes that do not pass through the voting process. In addition, there are subcommittee ballots for each item as it is being developed. This significantly increases the total number of ballots and adds to ‘ballot fatigue’. It also can become difficult to understand why the same ballot items seem to appear multiple times. For those where this causes problems, one strategy is to retract participation at the subcommittee level. This will eliminate almost half of the total ballots while still having an opportunity to review and vote on every item at the main committee level (final vote).

Requiring periodic manufacturer training for compliance to ASTM standards exists in many industries. From environmental compliance to flammability requirements for clothing, many standards-regulated groups agree globally that a culture of trained personnel is beneficial for actual compliance and the peace of mind that comes from it.

Last January, Light Sport Aircraft (LSA) ASTM Subcommittee F37.70 on Cross Cutting issues, voted on the addition of section 12 to F2972, Standard Specification for Light Sport Aircraft Manufacturer’s Quality Assurance System, which requires periodic manufacturer training. Section 12 requires those individuals who sign statements of compliance, within the Quality Assurance Administration (QAA) of an organization, to have taken and passed a training program which meets the requirements of Practice E2659 (E2659-09ε1 or the Standard Practice for Certificate Programs, which provides guidance for developing and administering quality certificate programs) and F2972-14. Despite the passage of this standards change, there seems to still be a great deal of controversy surrounding it within the LSA industry.

Currently there is no required ‘check point’ in the self-certification process that verifies a baseline level of understanding of compliance. Some nominal, industry-wide standard will be helpful. This is part of a larger, two-pronged approach to improve education about compliance and help the industry retain as little formal oversight as possible from authorities. The training requirements ensure that any individual signing a Statement of Compliance has an understanding of the standards and how they apply to aircraft.

A Brief History

For those not familiar with the history of this new requirement, it was 2010 when the F37 Executive Committee first recommended the development of a training program, and there was quite a bit of resistance to it. Required training was just one item in a prioritized list presented at the July ASTM meetings in Oshkosh, WI in response to FAA concern over the industry as a whole. Later that year, the FAA recommended the development of a third-party training program. Over the next two years the FAA became increasingly insistent that the industry demonstrate consistent and competent self-regulation before they (the FAA) had to take additional action, which was unlikely to be beneficial for light aviation. The ballot including a training program was first introduced at the September 2013 meeting and would be brought to vote four times over the course of the next year.

Over the course of the ASTM consensus process, there were persuasive negatives in four key areas on the ballot. First, there were concerns about the course cost, sustainability and complexity. The second persuasive negative was over the frequency of recurrent training. Third was a concern related to the scope of the standard itself, and the final persuasive negative was a desire to see the allowance of additional methods of compliance.

Each of these were discussed at meetings and carefully reworked by the task group until the ballot passed in 2014 October with only two non-persuasive negatives.

Going Forward

If the vast majority of aircraft delivered are truly compliant to the standards, then the industry will be much more healthy long-term. This will be especially true under the scrutiny of governments and media when fatal accidents occur. In addition, the FAA has given the industry a pretty long leash already, but we haven’t stepped up adequately. We can choose to shape our own future through engaging the standards-making process for what we do, or we can let regulators try to do it for us through their bureaucracy.

The ASTM standard allows for anyone to offer a training course that fits the bill, including manufacturers developing courses internally. There is one course available through ASTM as well. Currently the course is two full days with certificate testing for an additional fee.

Sebring, FL Just prior to the 2010 LSA Expo in Sebring, Florida, Adam Morrison and Severin Kempf of Streamline Designs led ASTM meetings related to Light Sport Aircraft standards. Adam serves as Chairman of the fixed-wing subcommittee as well as overall committee Vice-Chairman and Severin serves as Task Group Technical Contact for the development of a new audit standard for LSA. The meetings covered subject matter such as Electric Propulsion Units (EPU), IFR/IMC operations, audits, integrity of engine installations, and improved internationalization of the standards.

Just prior to the 2010 LSA Expo in Sebring, Florida, Adam Morrison and Severin Kempf of Streamline Designs led ASTM meetings related to Light Sport Aircraft standards. Adam serves as Chairman of the fixed-wing subcommittee as well as overall committee Vice-Chairman and Severin serves as Task Group Technical Contact for the development of a new audit standard for LSA. The meetings covered subject matter such as Electric Propulsion Units (EPU), IFR/IMC operations, audits, integrity of engine installations, and improved internationalization of the standards.

Severin had the following to say after these meetings, “Although there are many interests represented on the ASTM LSA standards committee, the ASTM process has proven to be very robust. At the end of the day, there was consensus to do the right things. I was also pleased to see that there is general agreement within the community as it relates to the developing audit standard for LSA.”

Adam noted following the Sebring meetings, “There are some very exciting things happening within the LSA industry. Aircraft designs and manufacturers are maturing and the industry is beginning to appreciate the value of high-quality consensus standards. We are on the forefront of electric propulsion and are actively developing standards to help assure that these systems can be safely operated. Developments are happening quickly, and the consensus standards process is proving well-suited to support the safety of significant innovations. Streamline Designs is ready, as always, to continue supporting this growing industry.”

Streamline Designs has been involved with the LSA industry since its inception and provides affordable, high-quality engineering services ranging from detailed design and analysis to setup of manufacturing quality systems to management and execution of complete compliance programs for LSA. For more information on these and other services, please contact us.

Indianapolis, IN In early 2008, Streamline Designs finished the complete rewrite and redesign of the Jabiru J250-SP Pilot’s Operating Handbook in accordance with the current requirements of ASTM F2245. The newly refreshed handbook was featured among others in EAA’s Sport Pilot and Light Sport Aircraft. The comments in the magazine were very complimentary of the POH.

Streamline Designs offers technical communications solutions at any level of involvement needed. We have worked with clients to audit existing technical manuals, redesign existing manuals to meet the international standards requirements, manage tracking databases for fielded manuals, refresh graphics and manual content, and more. Cost for these services varies depending on the nature of the project, but our rates are extremely competitive.

So whether your manuals need to be refreshed or if they don’t even exist yet, we have the skills and expertise necessary to capture your vision and we would love to see your technical manual featured here in the future.
POH Weight and Balance

To see the full article which includes the redesigned J250-SP Pilot’s Operating Handbook, click here:

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Testimonials

Adam and his team were involved in all aspects of the process from planning to technical publications development, as well as in direct support of the audit. His knowledge of the ASTM consensus standards and the FAA regulations for Light Sport aircraft is unparalleled, and the impact to our success has been immeasurable.

Bill JamesVP EngineeringICON Aircraft

It was good to relate the training to things I see and do every day.

Regarding the ASTM Standards Course for LSA

It gave me a very different perspective on not only the efforts of the original design to meet all the requirements, but also the discipline that had to be instilled early to prove compliance

Regarding the ASTM Standards Course for LSA

I think this is a class that every individual at the company would value from in some shape or form. It gave information which ranged from interesting to practical and by the end of the two days I not only understood much more about why we do certain things as part of our process and what more we could be doing to make our lives easier.

Regarding the ASTM Standards Course for LSA

Loved it. It was great to get everyone from various groups together to understand where we came from, and what we are required to do from regulatory standings. I always enjoy continuing my learning, so any more classes offered I will definitely sign up for.

Regarding the ASTM Standards Course for LSA

Streamline Designs played a critical role in the successful completion of the ICON A5’s FAA audit.

Bill JamesVP EngineeringICON Aircraft

After we hired SD, they made the entire certification process seem very easy.